Here is Karen’s well researched response:

OVERVIEW ARTICLE:

http://www.salon.com/food/feature/2010/04/26/usda_testing_end_local_meat/

Personal note: Hi! After reading the above article I started looking around for the letter writing campaign referenced in the last paragraph.  I was disappointed to find nothing easily assessable and nothing really geared toward consumers, it was all for the industry folks.  So I did my homework on the AAMP (American Assoc of Meat Processors – http://aamp.com/Validation.php) and after much reading and talking directly with one of their members, put together a letter for consumers.  My initial strong feelings were to slant the letter toward the evils of large, corporate processers vs. small, local, independent processors…but that’s NOT what this fight is about.  It’s about making sure that our small, local, independent processors are still standing and in business at the end of this!  If not for them, where will we take our local, well-cared for, grass-fed livestock to be processed?!  THANK YOU for your efforts to help save your local processors.

DEADLINE for COMMENTS: June 19, 2010

Definition of terms:

HACCP – (Hazard Analysis and Critical Control Points) is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. (SOURCE: ADA.org)

FSIS – Food Safety and Inspection Service

What YOU can do NOW:

OPTION 1:  Contact FSIS via email at:

DraftValidationGuideComments@fsis.usda.gov

Cut and paste the letter (making sure to fill in the highlighted areas and edit as you see/feel fit)

OPTION 2:  Make your changes and send off the hard copy letter to the address at the top

Docket Clerk, FSIS

Room 2-2127

5601 Sunnyside Avenue

Beltsville, MD  20705

Re: Comments – Draft Guidance on HACCP System Validation

Dear Mr. Almanza:

I respectfully submit these comments regarding the Draft Guidance on HACCP System Validation that were publically released on March 19, 2010.

As a consumer of livestock products who depends upon local, small independent meat processors, my concern regarding the process validation in inspected establishments HACCP programs has prompted me to submit these comments.  I am not an industry big-wig; I am only one person who is concerned with the damage that I foresee these new validation requirements causing my local, independent meat processors.  When HACCP was implemented, the meat industry saw a decrease in establishments.  This initiative and new interpretation has the potential to decimate the remaining very small to small establishments, upon which so many Americans, including myself, depend.  There is nothing wrong with the current HACCP system, whereas independent, small processors are concerned – nor is there any reason to believe the extraneous requirements would produce a safer end product.  It has been estimated that the potential cost to validate a processors entire food safety system could easily run upward of $500,000 initially and over $100,000 for ongoing validation.  No food safety problem has been identified to require this shift in agency interpretation of validation; I don’t understand why this is necessary when there is a system in place that is working.  All I see this shift in interpretation accomplishing is:

• Devastating the remaining small meat processors (hinders commerce)
• Large decrease in the variety of products available
• Discouraging the introduction of new products, therefore reducing the number of employees (increased unemployment)
• Increasing the cost of production, therefore increasing what I have to pay

None of these sound like they would be for the good of the American consumer.  I know, believe in and trust my local meat processors; therefore,   I respectfully request that the Draft Guidance on HACCP System Validation be revised to clearly state that no in-plant microbial testing is required when an establishment is following the long-standing, safe processes of HACCP.

I appreciate the chance to comment on the Draft Guidance on HACCP System Validation.  Thank you for your time and consideration.

Sincerely,

(Name and Address)

cc: [Your State Legislators- Congressmen and Senators]

[The Small Business Administration]

[Your State Farm Bureau]

[Your State Beef and Pork Council]

——————————————————————————————————————-

Find your Representative:

https://writerep.house.gov/writerep/welcome.shtml

Find your Senator:

http://www.senate.gov/general/contact_information/senators_cfm.cfm

Find your State Farm Bureau:

http://www.fb.org/index.php?fuseaction=newsroom.statefbs

Find your State Beef Council:

http://www.beefusa.org/affiFederationofStateBeefCouncils.aspx

Find your State Pork Council:

http://www.nppc.org/aboutus/stateassociations.htm

FURTHER ACTION YOU CAN TAKE:

Please also contact the Small Business Administration Ombudsman, which offers the opportunity to submit online comments on regulatory unfairness for small business. The website is:

http://web.sba.gov/nocms/client/dsp_welcome.cfm

Instructions:  (unblock pop-ups)

Organization Type: SELECT “Small Business”

Federal Agency Name: USDA

Agency Contact person:  Mr. Almanza

Agency Office/Division:  FSIS

Click “No”

ENTER:  AAMP

COMMENT:

I am writing re: HACCP System Validation for Meat Processors. When HACCP was implemented, the meat industry saw a decrease in establishments. The current initiative and new interpretation has the potential to decimate the remaining very small to small meat processing establishments. If the interpretation goes through as it is currently structured, it will most definitely be a hindrance to commerce, will decrease the variety of products available and discourage introduction of new products. This will in turn, reduce the number of employees needed and increase unemployment. It will also increase the cost of production, therefore increasing the cost I will have to pay. All of these factors alone represent unfairness toward small processors, when adding the financial burden (initially upwards of $500,000 and $150,000+ for ongoing verification) it surely must be regulatory unfairness for small businesses.  Thank you for your time and attention to this important matter.

OR you can send them a copy of your letter to FSIS/Mr. Almanza via regular mail at:

U.S. Small Business Administration

409 3rd Street, SW

Washington, DC 20416

5/7/10 - Opportunity to Give Input on AFRI RFA: The USDA’s National Institute of Food and Agriculture (NIFA) is accepting public comments on its Agriculture and Food Research Initiative

(AFRI) to help guide the development of the 2011 Requests for Applications (RFAs).

5/5/10 – USDA Seeking Public Input on Animal Disease Traceability: The USDA Animal and Plant Health Inspection Service (APHIS) announced the first three of a series of public meetings where stakeholders can offer input on the framework for a new APHIS rule on animal disease traceability.

Congressional News

5/7/10 – Food Safety Bill Still Pending in the Senate: S. 510, the Food Safety Modernization Act, is expected to be considered by the Senate right after the Memorial Day recess, according to Senate staff.   The bill is the first significant effort to increase food safety in decades and gives the Food and Drug Administration (FDA) new enforcement authority over industry and will also have a significant impact on farmers.

5/5/10 – Organizations Urge Congress to Fund Farm to School: This Monday, May 3, NSAC and 40 other national agriculture, health, and food business organizations delivered a letter to House and Senate Congressional leaders urging them to include $50 million in mandatory funding for programs linking farmers with local schools as part of the 2010 Child Nutrition Act reauthorization.

The FRFA sign-on letter in support of these amendments now has 114 signatories, and  continue adding until the bill goes to the floor.  If your organization wants to sign on, please email Judith McGeary, FARFA, at jmcgeary@att.net or Margie MacDonald, WORC, at mmacdonald@worc.org

State, Federal Officials Seek Insight on Fresh Produce Processing, Handling

HARRISBURG, Pa., April 27 /PRNewswire-USNewswire/ — Pennsylvania produce growers and food processors are invited to share their input on the U.S. Food and Drug Administration’s new produce handling rule at a May 13 listening session in Harrisburg, Agriculture Secretary Russell C. Redding said today.

The session will be held from 9 a.m. – noon at the Pennsylvania Farm Show Complex & Expo Center.

“As leaders in producing a variety of agricultural products, Pennsylvania produce growers and food processors are in position to offer valuable insight in national food safety discussions,” said Redding. “It is important that our industry take advantage of the opportunity to help shape federal policy regarding production and processing activities.

“By hosting this listening session, Pennsylvania continues to be a leader in the production of a safe, abundant food supply.”

Redding, state Health Secretary Everette James and FDA Deputy Commissioner for Foods Michael R. Taylor will attend to hear concerns and answer questions. The listening session will also feature presentations by produce industry professionals.

The listening session is intended to ensure Pennsylvania’s agriculture and food production sectors and public health partners keep pace with changing federal regulations.

“Locally grown produce is an essential component of a healthy diet, but outbreaks have shown it can also be a source for food borne illness,” said James. “It’s important for Pennsylvania farmers to provide the FDA with input to ensure that new food safety regulations protect their businesses and the public health.”

Redding and James co-chair the Governor’s Food Safety Council, a unique group of agriculture, health and emergency management professionals convened by Governor Rendell in 2009. The council advises the Governor on developing and implementing food safety, defense protocols and best practices in the state.

The listening session is open to the public and registration is requested. To register, contact Jared Grissinger at 717-705-9513 or jgrissinge@state.pa.us

Media contacts:

Nicole L. C. Bucher, Agriculture; 717-787-5085; Claudine Battisti, Health; 717-787-1783

http://www.agriculture.state.pa.us

With Congress back in session, wheels began turning on the Senate food safety bill, S510. On Wednesday, we reported on a number of important improvements that have been added to the manager’s amendment that will support small and mid-scale farmers, local and regional food systems, conservation, and organic farming. Though the timing of the bill has been pushed back to make way for a debate on finance reform, NSAC intends to continue to maintain these improvements throughout the process. Thank you to all who flew in for a visit or made a call — your voice has been heard!

As always, to access the full articles and leave comments, visit our “Something to Crow About” Blog.

USDA News

4/13/10 - Research Grants Drilldown: Conventional Breeding and Climate Adaptation

The overarching goal of the RFA is to reduce use of energy, nitrogen, fertilizer, and water by ten percent and increase carbon sequestration by fifteen percent by the year 2030.  While this goal focuses on mitigation, most of the programs in the RFA focus on strategies for climate change adaptation.

Congressional News

4/16/10 – Senators Chide Administration on “Actively Engaged”

A bi-partisan group of Senators sent a letter to President Obama on Tuesday criticizing the Administration’s loose interpretation of “active personal management” in the United States Department of Agriculture’s (USDA) final rule on farm program payment limitations, released on January 7, 2010.

4/14/10 - Senate Food Safety Bill Includes Improvements That Support Farmers

In most areas of the legislation, sustainable agriculture and family farm groups think the Senate bill is a very significant improvement over the companion bill passed by the House of Representatives (HR 2749) last year.   If the Senate passes the bill next week or soon thereafter, it will head to a conference committee to work out differences between the two bills.

The report shows that 12.3 percent of all foodborne illness outbreaks from 1990 to 2007 were associated with produce. Just over 10 percent of all identified outbreaks were associated with improper handling after leaving the farm and 2.2 percent were associated with the growing, packing, shipping or processing of produce. The majority of the foodborne illness outbreaks, 88 percent, are from non-produce food items…

…The report also concludes that improvements are still necessary when it comes to training and educating both consumers and restaurant employees on safe handling of produce. Findings show that 65 percent of outbreaks traced back to a produce item can be attributed to improper handling in a restaurant, most likely the result of cross contamination or improper employee hygiene. Mishandling at community events caused 14 percent of the produce-related outbreaks, followed by mishandling in the home which represents 13 percent of outbreaks associated with produce…

To read the entire article click HERE

Proposed Measures Follow Recommendations of Food Safety Working Group

WASHINGTON, March 25, 2010 – The U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) today announced that it is seeking comment on proposed measures to enhance food safety. The proposed rule would implement a provision of the 2008 Farm Bill and is a priority for the Food Safety Working Group (FSWG).

“One year ago the President called on government to do more to ensure our food is safe, and we are working aggressively every day to improve the food safety system in the United States,” said Agriculture Secretary Tom Vilsack. “The steps we are announcing today will help prevent foodborne illness as well as speed our response when illnesses occur – two goals of the Food Safety Working Group.”

The new proposed rule would require that regulated establishments: 1) Promptly notify FSIS if any unsafe, unwholesome or misbranded meat or poultry product has entered commerce; 2) Prepare and maintain current procedures for the recall of meat and poultry products produced and shipped by the establishment; and 3) Document each reassessment of the establishment’s process control plans or Hazard Analysis and Critical Control Point (HACCP) plans.

The new proposed rule supports the Food Safety Working Group Key Findings announced on July 7, 2009. President Obama created the Food Safety Working Group on March 14, 2009 and charged Vilsack and Health and Human Services Secretary Kathleen Sebelius, the co-chairs of the group, with working to upgrade our food safety laws for the 21st century; foster coordination throughout government; and ensure that we enforce these laws to keep the American people safe. Representatives from all federal food safety related agencies, including FSIS, the Food and Drug Administration, and the Centers for Disease Control and Prevention meet regularly to discuss how producers, processors, retailers, consumers, and all levels of government can work collaboratively to make the food Americans eat as safe as possible.

Comments regarding the adopted regulations must be received on or before May 24, 2010, through the Federal eRulemaking Portal at www.regulations.gov, or by mail to: Docket Clerk, U.S. Department of Agriculture, Food Safety and Inspection Service, Room 2-2127, George Washington Carver Center, 5601 Sunnyside Avenue, Mailstop 5474, Beltsville, MD 20705-5474. All submissions received through the Federal eRulemaking Portal or by mail must reference the Food Safety and Inspection Service and include the docket number “FSIS-2008-0025.”

For further information, contact Philip Derfler, Assistant Administrator for the Office of Policy and Program Development, FSIS, U.S. Department of Agriculture, Room 350-E, Jamie L. Whitten Building, 1400 and Independence Avenue, SW, Washington, D.C. 20250-3700, by phone (202) 720-2709, fax (202) 720-2025, or e-mail Philip.Derfler@fsis.usda.gov.

More information on the Food Safety Working Group can be found at www.foodsafetyworkinggroup.gov.

At a hearing on March 10, members of the House Agricultural Appropriations Subcommittee had high praise for the FDA’s stepped-up food safety enforcement efforts during Commissioner Margaret Hamburg’s tenure.  Inspection efforts will undoubtedly increase even further if Congress moves forward with pending food safety legislation.   Hamburg thanked the House members for their passage of food safety legislation, and said she hoped that the Senate would follow suit without delay.

Although the Senate version is similar to the House version in some respects, the bills diverge with regard to who should foot the bill for stepped-up inspection efforts.  To help pay for inspections, the House measure imposes a flat tax on all food processing facilities, including hundreds of thousands of farms that either minimally process their crops to prepare them for market or that engage in value-added activities.  An identical $500 per facility per year tax in the House bill would apply regardless of the size of the operation.  The farmer selling a few thousand dollars worth of product to the local coop would thus pay the same as a large multinational corporation with millions in sales.

The Senate bill, in contrast, does not rely on new taxes except for fees to repay the government for costs in food safety corrective actions.

At the House Subcommittee hearing, Chair Rosa DeLauro (D, CT) pressed Commissioner Hamburg to fight for the fee structure set forth in the House’s version of the bill.  DeLauro noted that the House version raises $220 million in “user fees” while the Senate version raises only $65 million.  Said DeLauro, “we shouldn’t proceed to major food safety reform and then doom it to failure” because of inadequate funding.

Any funding not provided for by the user fee or tax would have to be provided for via appropriations from DeLauro’s Subcommittee.  Even in the House-passed food safety bill, however, the majority of the new costs resulting from the proposed new law would come from appropriations because the fee is only big enough to cover a fraction of the cost of the legislation.

NSAC is opposed to the highly regressive flat tax in the House bill, which is designed to hit small farms and small local processors hard while allowing food industry giants to sail through relatively unscathed.

We would support the no-fee Senate approach over the House regressive flat tax if in fact those are the only two choices.  NSAC would, however, support a fair, well-designed tax that was progressive, with exemptions for small producers and processors and three or four graduated levels above the exempt level.  In other words, if the tax were based on the time-honored “ability to pay” principle, and included a basic exemption level below which it did not apply at all, it might be acceptable.

NSAC will continue to continue to oppose a flat tax and will work for either no fee, as in the Senate bill, or a reasonable, progressive fee structure.  The Senate bill is expected to go to the floor for a vote between Easter and Memorial Day.  After that it will need to be reconciled with the already passed House bill.  To stay informed of NSAC’s work, sign up for our weekly roundup and action alerts.

Read more at: http://sustainableagriculture.net/blog/fda-commissioner-hamburg-fields-questions-about-food-safety-fees/

CONTACT:  Deborah Stockton 434.295.7176 Email: nicfa@earthlink.net
Congress Gets Fed a New Taste of Food Safety

March 8, 2010–Washington DC—The National Independent Consumers and Farmers Association (NICFA), along with a host of area restaurants and caterers who source food from local farmers, plans a buffet reception for federal legislators on March 10, 4:00 – 6:30pm Room SD-106, Dirksen Senate Office Building, Washington DC.  Citing potential destruction of small farms as the unintended consequence of proposed federal food safety bills, the national advocacy group is bringing to Congress its message that small farms produce the safest food.

The buffet will cap off the fourth annual Farm Food Voices lobby day (10:00am-3:00pm). This year, Main Event Caterers is coordinating food from a number of fine dining restaurants around the metro area, including Nora’s, Sonoma, Woodberry Kitchen, Poste Brasserie, Restaurant 3, Alchemy Caterers, Coppi’s Organic, Lavender Moon Cupcakery, Suburban Trading Company and Food Matters. The lavish buffet will be served up to Senators, Congressmen and their staffs, with a request to spare small farms more legal hurdles.

“Small farms produce the safest food available, without regulation. Small farms are also  increasing at about 13,000 a year, according to the USDA,” says Deborah Stockton, Executive Director of NICFA.  “The current Administration that wants to ‘rebuild’ rural America, is pushing food bills that will do the opposite.  Just like family farms brought us out of the Great Depression, they can bring us out of the food safety problem and this recession, if they are allowed to thrive.”

NICFA asserts that federal agencies do not enforce measures already on the books to ensure food safety in the industrial food system.

“Do we really want to give sweeping new powers to agencies that do not do their jobs?” asks Stockton.  “The main threats to food safety – by the government’s own admission – are centralized production, centralized processing and long distance transportation. The food safety bills will actually increase these risk factors by consolidating agriculture into fewer, larger industrial farms  through enormous regulatory burdens that small farms cannot endure.  There is not a history of food borne illness from farmers’ markets.”

Mrs. West Virginia International is also making a lobby day appearance at her representatives offices and the buffet. Beauty Queen, Mrs. Alexandra Booth will vie for the title of Mrs. America International with Local Food as her platform.

Advocates for the bills claim that exemptions in the bills will protect small farms. Consumers and farmers from around the country however, contend that the exemptions are insufficient and questionable, and they will ask legislators to reconsider these bills. For more information on the Capitol Hill local-foods reception see http://www.nicfa.com